Hong Kong Virtual Asset Licence Update: Key Changes YTL LLP

Hong Kong has established itself as Asia’s premier regulated hub for virtual assets. With the SFC’s ASPIRe Roadmap actively unfolding and a unified virtual asset licence regime under the AMLO arriving in 2026, staying informed on the latest regulatory updates is critical for any financial institution or fintech firm.

This article outlines some of the recent developments and their implications for your virtual asset licence strategy.

ASPIRe Roadmap: Shaping the Future of Virtual Asset Licences

Hong Kong’s regulatory approach has matured from experimental sandboxes to a comprehensive framework for institutional participation. The ASPIRe Roadmap, launched in February 2025, is the strategic blueprint transforming the market.

For firms, this means the focus has shifted to understanding the specific virtual asset licence requirements and opportunities that emerge from each pillar of the framework.

How ASPIRe Pillars Impact Licensing:

ASPIRe Pillar	Licensing & Operational Impact
Access (A)	Streamline market entry through regulatory clarity. Establish licencing regimes for OTC trading and custody services. Facilitates licence holders’ integration with global liquidity and markets.
Safeguards (S)	Sets mandatory custody standards; enhance insurance and compensation frameworks; clarify investor onboarding and product categorisation.
Products (P)	Liberalises token listing for licensed VATPs, expanding permissible product ranges
Infrastructure (I)	Modernise reporting, surveillance and cross-agency collaboration. Solutions for reporting and detection of illicit activities. Enhance local cross-agency collaboration, and cross border co-operation.
Relationships (Re)	Framework for finflucencers to address new investor engagement channels; cultivate communications and talent network.

Key 2025 Update: Liberalised VATP Token Admission Rules

A significant virtual asset licence update for Virtual Asset Trading Platform (VATP) operators occurred in November 2025. The SFC removed the mandatory “12-month track record” requirement for tokens offered exclusively to Professional Investors (PIs).

Implications for VATP Licence Holders & Applicants:

Faster Listings: Licensed platforms can now list new tokens, including stablecoins, in sync with major global exchanges, attracting international liquidity.
Enhanced Due Diligence Duty: Licence holders’ Token Admission Committees must now exercise “professional skepticism,” conducting deeper due diligence on smart contract risks, governance, and centralisation issues.

Operational Update: Integrating Global Liquidity

To solve market fragmentation, the SFC now permits licensed VATPs to integrate order books with affiliated global platforms under its Liquidity Sharing Circular.

Licence Compliance Note: Implementing this requires:

Prior SFC Written Approval: A mandatory step before launch.
Strong DVP Controls: Robust Delivery-versus-Payment systems are essential to manage cross-jurisdictional counterparty risk, a key focus for regulators.

This update significantly enhances the competitiveness of a Hong Kong virtual asset trading licence.

The Major 2026 Licence Update: Unified AMLO Regime

The most transformative virtual asset licence update is scheduled for 2026. The current system will be replaced by a comprehensive statutory licence framework under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO).

This new regime will introduce specific licence types for:

Virtual Asset Dealing
Virtual Asset Custody
Virtual Asset Advisory
Virtual Asset Portfolio Management

Critical Change for Asset Managers: The existing 10% de minimis exemption will be removed. Any portfolio management involving virtual assets, regardless of proportion, will require a formal SFC licence.

Proposed 2026 Licence Capital Requirements (Draft):

Proposed Licence Type	Minimum Paid-up Share Capital	Minimum Liquid Capital
VA Dealing (with Custody)	HKD5,000,000	HKD3,000,000
VA Advisory	HKD5,000,000	HKD100,000
VA Custody (Standalone)	HKD10,000,000	HKD3,000,000

Actions

This is a crucial window for strategic positioning.

Licence Gap Analysis: Audit your current and planned activities against the proposed 2026 virtual asset licence categories.
Capital & Compliance Planning: Prepare for the significant capital requirements (e.g., HKD 10 million for custody) and enhanced operational standards.
Phased Implementation: Use 2025’s product liberalisation to build market presence, while aligning your infrastructure with the forthcoming statutory licence rules.
Establish Trust Early: Firms that secure their virtual asset licence under the evolving robust standards will gain a significant “trust premium” with institutional investors.

Secure Your Competitive Edge in Hong Kong’s VA Market

Navigating the evolving virtual asset licence landscape requires precise, proactive counsel. Our team provides end-to-end hands on guidance—from licence application structuring and capital compliance to ongoing regulatory navigation—ensuring your firm is not just prepared, but positioned to lead. Don’t navigate these critical updates alone.